“EPA announced four public information meetings for the hydraulic fracturing study in the Federal Register (75 FR 35023) on June 21, 2010.”
Preamble
This is a set of comments listed as ‘Items’ intended to be public comments to be considered by the United States Environmental Protection Agency. These remarks are against and critical of the practice of ‘Hydraulic Fracturing’.
‘Hydraulic Fracturing’ is a process whereby a hole is drilled into the earth at a location where it has been determined or is believed to contain natural gas in such quantities that it might be commercially viable to attempt to extract it.
The process has not been settled into established specific practice but does have a general process which can be outlined. That process is that the locations for the possible gas quantities are determined, a hole is drilled to the layers that are the target and then a horizontal pipe bore will be extended in one or many ways from the original vertical hole. In this horizontal bore then liquid chemicals, high pressure water or steam or explosives (sometimes a combination of these or a succession of these) will be inserted into the bore and allowed to carry out their intended purpose.
Strictly speaking of ‘Hydraulic Fracturing’ the practice involves forcing high pressure water or steam into the hole in order to ‘fracture’ or put cracks in the layer or seam of material that it is believed contains commercial amounts of natural gas.
Oftentimes the introduction of high pressure steam or water is not enough to fracture the material sufficiently and other chemicals must be added to the mix.
In the case of the Marcellus Shale or sandstone deposits in question the chemicals that can be added to hurry along this process are varied and many are very dangerous because they are poisonous to humans and other forms of life.
At this time the Environmental Protection Agency either does not know what chemicals are being used or have been used or is keeping that information to themselves during secret proceedings to ‘determine’ the actual safety of these dangerous chemicals after being released into the environment by irresponsible and often poorly trained field technicians working for the companies intent on establishing working natural gas wells at these locations.
Item 1 - Social
The proposition has been put forth by various individuals in the gas industry that ‘a million wells have been drilled’. This may be the case and may be a reliable fact but it is a true statement and the truth to state that no one knows how many ‘Hydraulic Fracturing’ wells have been drilled in total. For that matter there is no reliable figure for the number of CO2/Sand Fracturing wells that have been drilled, nor are their figures for the number of wells that have used explosives for fracturing, nor figures for how many times the technique for ‘Formation Refracturing’ has been used. (‘Formation Refracturing’ is when the fracturing needs to be done again, either because it didn’t work the first time or because the hole began to close or became obstructed.
The point being here in Item 1 that arbitrary numbers associated with drilling holes into the earth being used as an underlying basis on which to build a logic allowing wide scale ‘Hydraulic Fracturing’ is a flawed idea and any of these individuals putting forward such logic should not be considered to be reasonable sources of information regarding the relative safety or usefulness of ‘Hydraulic Fracturing’.
Item 2 – Science
Fracturing can cause ‘quickening’ immediately or lead to ‘quickening’ after some period of time after the underground destruction has been performed.
In some locations there are high concentrations of liquids under conditions of extremely high heat and pressure. When certain strata in the rock is fractured it can release pressure on overlying or underlying layers which can lead to pools of trapped liquids, sometimes of very great size, to be released from their current chambers and speed unimpeded at the speed of sound to other areas where the pressure is less.
The path of these seams that are opened to these chemicals may lead to drinking water tables many miles away – anywhere from a few miles to over a hundred miles. This material will remain poisonous and can cause ‘sweet water’ to go ‘sour’ whether it be salt brine or salt brine heavily contaminated with arsenic or other poisonous chemicals – including any used in the ‘Hydraulic Fracturing’ process.
Local seismic imaging will not reveal these faults and cracks before the fracturing begins and they will be hard if not impossible to locate after the fracturing is completed because after evacuating the chamber of their liquids the seams will close again nearly instantaneously.
‘Quickening’ is a feature of mining, drilling and petroleum recovery as well as high-pressure injection operations that is familiar to offices of the Environmental Protection Agency and needs to be publicized before approving destructive process like ‘Hydraulic Fracturing’ or fracturing ‘technology’ of any type.
Item 3 – Economic
The State of New York’s Environmental Protection Office has not, it seems, fulfilled its duties as an independent environmental protection agency and so the State of New York is at fault in accordance with its agreement with the Federal EPA to meet certain standards when attempting to protect the environment from destructive practices such as ‘Hydraulic Fracturing’.
In this case, as it relates to ‘Hydraulic Fracturing’ in rural areas of the State of New York, the New York State Environmental Protection Agency has put profit before duty and appears to have been heavily influenced by so-called ‘Upstate Politicians’. Upstate New York, especially the area targeted for the destructive and unreasonable process referred to as ‘Hydraulic Fracturing’ is a source of drinking water for millions of Americans downstream of the hills, mountains, slopes and valleys that are about to be assaulted.
The Natural Gas industry and local politicians as well as the New York State Environmental Protection Agency itself may be unduly profiting while at the same time causing a shift of payments to the people, communities and businesses which have become dependent upon this water over the past century and a half.
The past 150 years has seen a great increase in growth and population in the region downstream of these proposed destructive operations and the costs associated with ill health, increased water treatment, increased environmental testing, loss of business, loss of quality of life are astronomical in comparison to the short-term profits that may be produced by allowing this type of brute force drilling across the area.
Item 4 – Social and Economic
There are long standing agreements between New York City and New York State explicitly and implicitly protecting water rights for the city and its many suburbs. These have not been visited and New York City itself, under Mayor Bloomberg, has, in my opinion, not taken due diligence in regards to his fiduciary duty as Mayor to protect and uphold the laws of the City and State of New York as well as to protect the people and children of the City of New York.
Governor Paterson, likewise, in my opinion, locked in political battles and unaware or willfully neglecting the importance of clean, fresh water to an increasingly polluted state has not apparently performed his fiduciary duties in this case to ensure that one region of New York does not unduly profit at the expense of the rest of the state as well as its neighbors.
The states of New Jersey and Pennsylvania also, apparently, have interests in this issue though in this case because of the location of many of the properties many of the remarks concerning the State of New York also apply to the State of Pennsylvania which historically has neglected its duty towards quality of life for its citizens in the face of even the barest opportunity of profit or cash savings.
Item 5 – Economic
There is no guarantee that the profits that have been promised by the drillers will materialize. In fact, some aspects of the entire scheme and gigantic parts of it at that, appear to be nothing more than a house of cards.
For example, if two competing companies, or even the same drilling company, arranges financing to purchase mineral rights for an area and drills and starts to produce – there is no guarantee how long those wells will produce or even if they will produce at all.
It is possible that during this destructive practice that much of the gas that is being sought will be lost through the same cracks that are being opened to collect it. In that case the gas can then cause additional problem through the poisoning of the soil or by mixing with heavy metals already present in the soil to produce even more exotic and dangerous environmental chemicals.
Issues in Western New York involving the poisoning of entire valleys and large portions of the region because of 19th century tanning and mining operations is well known throughout New York State. A problem with veracity is encountered when we consider these other poisons because not speaking about them does not make them go away – in fact – this is a possible case of lying by omission by the New York State Environmental Protection Agency if they did not inform the drillers themselves the high stakes game they were entering into.
If the New York State Environmental Protection Agency did not report these potential problems to the greedy speculators then they would be at fault.
Item 6 – Environmental
The Federal Environmental Protection Agency and the New York State Environmental Protection Agency have a mandate to protect drinking water tables – this drilling and destruction will take place far below the drinking water tables but will impact American citizens close to and very far from the work.
It appears that the Federal Environmental Protection Agency and the New York State Environmental Protection Agency may be pretending to be able to license or permit this activity when, in fact, the process is being abused by the greedy speculators in order to get permission to carry out these backward plans.
The Federal Environmental Protection Agency and the New York State Environmental Protection Agency have no jurisdiction over the area in which the activities are going to take place.
It is misleading to Americans then for the Federal Environmental Protection Agency or the New York State Environmental Protection Agency to ‘permit’ activities for which they have no control over.
These issues should be left up to local governments as well as the State government of New York which needs to rein in the out-of-control New York State Environmental Protection Agency.
Item 7 – Economic and Science
The Environmental Protection Agency of the United States permits ‘High Pressure Injection Wells’. These wells are put at risk when fracturing takes place near them or around them. There are so many of these types of chemical disposal wells in the United States that the Environmental Protection Agency of the United States doesn’t even know where they are.
These wells are drilled into and store chemicals at the same levels or just above or just below the area where these ‘Hydraulic Fracturing’ wells are to be drilled. If these chambers of noxious chemicals are disturbed or allowed even the smallest pathway back to the surface then permits and agreements that the EPA has had to guarantee that those wastes will not move for ten-thousand (10,000) years will become invalid.
The chemicals thus released will become a danger to generations to come and may be undetectable in the horrors they wreak for 10, 20 or 30 years or more.
Item 8 – Economic
‘Hydraulic Fracturing’ appears to be a dangerous sham.
It can be likened to a Pyramid Scheme in its financial arrangements.
There is no guarantee for profits nor guarantees for a more secure source of domestic energy.
There is guaranteed danger, however, with disaster waiting in the wings.
In the end it appears that this technique will not only NOT increase the available supply of domestic natural gas for consumption domestically in the United States but will cause disruptions in already established and strained supply lines and ultimately raise home heating, energy generation and transportation costs.
Item 9 - Economic
The United States Environmental Protection Agency, if it should go ahead and permit ‘Hydraulic Fracturing’ will succeed in crippling another industry which promised to be far more long-lived and profitable for many Americans.
Rather than the uneconomical destruction of real estate, water supplies and farmland the other industry which the Environmental Protection Agency stands ready to destroy is the renewable energy industry.
Solar panels, wind power and alternative uses of generators in rivers will be curtailed if not destroyed if money, time and effort is uneconomically channeled into the destructive and wasteful acts associated with ‘Hydraulic Fracturing’.
The Environmental Protection Agency will impede progress and interfere in the industrial development of locations far away from the locations it will apply its narrow set of powers.
Just as the Environmental Protection Agency inadvertently at first, and, heavy handedly in present times, uprooted, undermined and destroyed the recycling chemical industry, by encouraging this short-sighted assault on our national resources, the EPA will once again act as agent of economic retardation and reversal. The EPA should act as it is intended to act and not as a cog in the wheel of some hair brained schemes that ultimately leave us all the poorer.
In Quebec, Canada the recycled chemical industry is profitable and busy. There are many jobs and they do fine work keeping the price of chemicals down while quality high.
In the United States the Environmental Protection Agency has destroyed the recycled chemical industry by ‘permitting’ high-pressure injection wells. These wells are used to inject chemical waste into the earth. More than eighty percent (80%) of the chemical waste in the United States is disposed of in this manner. Until recently the EPA even allowed nuclear waste to be disposed of in this manner.
It is time for the EPA to leave the economic arena and step back into its regulatory position or it must be disbanded altogether as its original mandate has been corrupted and perverted beyond recognition. It should stop regulating trade and encoring uneconomic and wasteful practices. The EPA should stop putting Americans out of jobs.
Item 10 - Economic
The petroleum industry to this day burns off most of the natural gas it extracts from the earth when it is drilling for oil.
In a famous case just recently the ‘Deepwater Horizon’, owned by a foreign national corporation, exploded and sank in the Gulf of Mexico because the people running advanced drilling apparatus could not control the natural gas that they were extracting.
They had been burning it off in a giant flare.
When you see a refinery and the flares are burning hot, white, blue, orange and bright - that is a symbol of waste.
It is uneconomical to burn the fuel that could heat homes and power machinery but the petroleum industry does it because the Environmental Protection Agency allows them to do it.
Even though the gasses that they are burning would be more economically used by being trapped and stored the companies involved in that work continue to burn it off into the air because they don’t know how to handle the billions of square feet of natural gas that they collect when they are pumping mud and oil up out of the ground.
There is no economical need for ‘Hydraulic Fracturing’ right now.
It would be more economical to harness the wasted energy and power that is burned into the atmosphere without a care and without a price tag rather than to pursue wasteful and destructive practices like ‘Hydraulic Fracturing’.
In Closing :
The State of New York has made a serious mistake by allowing this process to go forward.
It should be apparent to the United States Environmental Protection Agency that is has strayed into territory beyond its mandate and it would be the truthful and scientific thing to admit this fact now before further mistakes are made.
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